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HINCKLEY, ALLEN, TOBIN & SILVERSTEIN THOMAS I COUUC.I K)HN I C.OWHL II

Attorneys at Law November 19, 1984

William Walsh-RogalskiRegional Counsel RECEIVED u.s. Environmental Protection AgencyRegion I John F. Kennedy Federal BuildingBoston, f.1assachusetts 02203 t;G10H l

OFFICE Of IEGJOtW. COUHSnRe: Western Sand & Gravel

Dear Bill:

Enclosed is the revised Hunt Chemical private well water monitor program. This reflects the understandings reached at the November 13, 1984 meeting.

Please give me a call if you have any questions regardingthis.

/1 enclosure ,.

/cc: Alan Brodd

Jack O'Grady Verrill Norwood Myron Sokolowski

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PHILIP A. HUNT CHEMICALOORPORATION

WESTERN SAND AND GRAVEL SITE

PRIVATE WELL WATER MONITOR PROGRAM

September 25, 1984

(Revised - October 31, 1984)(Second Revision - November 15, 1984)

Monitoring Program

The Monitoring Program will consist of a periodic sampling and analysis of all private drinking-water wells in the affected area, as defined by Arthur D. Little, Inc. in a report entitled "Remedial Investigation/Feasibility Study for Western Sand and Gravel,Burrillville, Rhode Island April 1984", as well as 9 additional lots identified by us EPA on Douglas Pike and Gig Road.

Purpose

The purpose of the Monitoring Program is to determine the effectiveness of the carbon absorption filtration systems installed by Philip A. Hunt Chemical Corp. as a remedial measure to improve the drinking-waterquality in the affected area. Additionally, data will be developedwhich may help to better delineate the extent of contamination and the general improvement or decline in water quality over time in the affected area. Another important feature of the Monitoring Programwill be the development of data to determine if any additional homes in the affected area have contaminated water supplies. Bacteriologicalquality of the treated water will also be assessed. The results will enable P.A. Bunt to develop the necessary support system to provideperiodic replacement of the carbon media, as necessary, to insure the proper performance of the filtration systems and installation of back­up filters for any newly-contaminated water supplies.

Parameters and Freguency of Testing

All private drinking-water wells in the affected area, and any others which have filters installed by HUnt, will be sampled and analyzed for all parameters listed in Tables I and II, per the schedule shown in Table III. Periodic sampling and analysis for coliform bacteria wi ll also be conducted as an integral part of the monitoring program.

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PHILIP A.HUNT CHEMICALCORPORATION

Reporting

Results will be reported monthly during initial testing program, quarterly thereafter. Hunt will submit a monthly report for each month in which site activity occurs.

Reports will be submitted to US EPA/RI OEM within 10 days of receipt of laboratorv data. Hunt will notify EPA Project Officer 5 days prior to any sampling activity.

Filter Maintenance

Upon receipt of positive results in previously uncontaminated wells, Hunt will, as soon as possible, obtain a second sample and repeat the analysis. If the repeat analysis is positive, Hunt will install a second carbon treatment and treat the home as other contaminated homes.

In the event that analysis indicates break through of the first carbon treatment unit, Hunt will, as soon as possible, recharge the unit with fresh carbon.

Hunt will submit a filter maintenance schedule indicating frequency of sampling and recharging after the completion of the initial testing program.

Hunt will repair or replace any filter which has plugged or become otherwise inoperable. If physical plugging of the units becomes a problem, Bunt reserves the right to install prefilters. Bunt agrees

· to make a diligent effort to insure the effectiveness of the filters, and meet with EPA/OEM to discuss any problem areas. Hunt ·agrees to notify EPA/OEM in writing of any and all homeowners refusing the treatment systems after all efforts to convince homeowners to accept the systems have failed.

Bunt agrees to submit a QA/QC plan within 10 working days of acceptance of ··Bont • a sampling program. · QA/OC plan to include lOt duplicates and field blank for e~ch sampling day.

Bunt agr es to use testing laboratories utilizing standard EPA test m thods. Bunt agrees to utilize normal accepta.ble chain of custody procedures and sampling protocols.

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PHILIP A.HUNT CHEMICALCORPORATION

Project Coordinator

Hunt agrees to submit the name and address of its project coordinator within 10 working days of acceptance of Hunt's sampling program.

Filter Installation

Hunt agrees to continue its diligent efforts to install filters in all homes in the affected areas, as defined by ADL, plut lots 68, 378, 37, 37A, 36A, 35, 43/48 & 36. Dual filters will be offered all homeowners in lots 41/41A, 42, 42F, 44, 45, 55, 62, 36, 37, 42A & 43/38. Dual filters presently exist at lots 72 and 59. Hunt agrees to install water meters on all homes receiving dual filters.

Consultations with USEPA/RIDEM

Hunt agrees to meet with USEPA/RIDEM at least twice during the first year of the Monitoring Program, at the following milestones:

(a) After completion of sampling, analysis and interpretation of results from the initial sampling round, and completion of Hunt's isotherm pilot study.

(b) After completion of sampling, analysis and interpretation of results of six monthly samplings of the 13 wells identified by EPA as being contaminated, listed under Filter Installation, above.

The purpose of the meetings will be to discuss the progress of the Project, and to evaluate the frequency of sampling.

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PHILIP A.HUNT CHEMICALCORPORATION

TABLE I

Private Well Water Contaminants in Affected Area

1,2 Oichloroethene * 1,1 Oichloroethane *

Tetrachloroethylene * 1,1,1 Trichloroethane *

Dichloromethane *

*Data obtained from private well treatment recommendations September 10, 1984 Camp Dresser and McKee

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PHILIP A.HUNTCHEMICAL CORPORATION

TABLE II

Additional contaminants of interest as indicators

Xylene * Toluene *

*Contaminants known to exist at the Western Sane and Gravel Site per previous studies by G.ZA/ERA

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PHILIPA.HUNTCHEMICALCORPORATION

TABLE III

SErrl'ED PAIWEl'ERS ~ 1) ll ~(a) Calventiooal (.. ) PER TABLE I & II (V(X:) BACTERIA Parameters

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M:lnthly (2)Q:ntaninated wells Moothly Qle time ally with treatltw'm influent and effluent (5 ) effluent (,) influent

Quarterly influent

Quarterly influent No sanpling (7 ) No sanpl.in:J

h)Other peaks identified and quantified by 601/602 method, if present.

h)For at least six J1'alths quarterly thereafter.

(,)IU:'e frequently if initial eq>l.inq indicates necessity.

(.. )Ccl1venti.alal, panmet.ers will incl\de: 'lbtal organic carlxln, il:al Dll!lngan888, oolor, blrllidi ty and Iii·

(s)Bffluent fran t;b:)ee with dual fllters shall be the first spigot ~le . after each carba\ unit.

(,)Effluent fran those with single filter shall be the first spigot after the carlxln unit.

(,)Effluent eatple for ooUfcmn bactleriA shall be taken at the first spigot after the treatment systan.

1( ) H\.1\t agrees to 11\ake an fort to obtain ool.i.fotm urpl.ea during the nmning

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